Privacy Policy

Privacy Policy for Personal Information

of

Lorraine Janet Irlam,

Registered Clinical Counsellor

(Also operating as “My Therapy Online”)

 

Introduction

BC’s Personal Information Protection Act sets out rules for how organizations collect, use and disclose personal information.

I am committed to protecting the privacy of people whose personal information is held. All clients, professional helpers, and visitors to this site must be treated with personal human care, outstanding ethics, and integrity. I undertake to honour or exceed the legal and ethical requirements of information privacy that apply in British Columbia through responsible information management practices. Any personal information you provide is collected, used, and disclosed in accordance with the ethical codes of the BC Association of Clinical Counsellors and the Personal Information and Protection Act of British Columbia.

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

* Last name

* First name

* Street Address (home)

* Telephone number

* E-mail address

* Credit card information

* Age

* City

* Province

* Country

* Postal Code

* Telephone Area code

* Time Zone

* Best times to call

* Occupation

* How clients found out about our services

* Visits to our web sites

Personal information also includes:

* opinions, evaluations, comments, social status, or disciplinary actions; and

* employee files, credit records, loan records, medical/counselling records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)

The purpose of the collection, use and disclosure of your personal information is for the provision of and billing for professional counselling, including supervision for the purposes of improving provision of such counselling services and may include related purposes such as verifying identity. Your personal data, with identifying information removed, may be used for the purpose of data analysis and improving services. I will only collect, use or disclose personal information that is necessary to fulfill the purpose of the collection.

Consent

I will obtain your consent to collect, use or disclose personal information, except where I am legally authorized or required by law to do so without consent. I will notify you of the need to collect, use and disclose personal information during the informed consent process, whether orally, in writing or electronically. This consent may be implied or express, depending on the nature and sensitivity of the personal information.

I may collect, use or disclose employee information without consent if it is reasonable for the purpose of establishing, managing, or terminating an employment relationship between me and the employee.

You may opt out of future consent, but that may result in my no longer being able to continue to provide you with my services, or other possible consequences, which we can discuss at the time.

Exceptions

In accordance with Canadian laws and ethical codes of the counselling profession, I assure you that I will not communicate your Personal Information to anyone without your consent – with the following exceptions:

  • If I believe that a person may be at risk of serious harm to self or other [including – for example – potential suicide, homicide, or driving while intoxicated], I must report the situation to appropriate authorities and/or your emergency contact person and/or the endangered person.
  • Courts of law have the power to demand that I release your records and by law I must do so.
  • In order to give you the best possible service, and as required by accepted ethical counselling
  • practice, I may consult with other qualified counsellors from time to time. This may
  • involve the consultant having access to your personal information and counselling records.
  • In the event of technology failure and need for technical support, the technician may see some of your information [for example, technicians at Hushmail – providers of encrypted email – would be able to see email address and subject line].
  • If you have an unpaid debt to me, and if I choose to take legal or other action to collect the debt, including engaging the services of a third-party collection agency, you waive your right to confidentiality, to the extent permitted by the Personal Information Protection Act of British Columbia.
  • If you name me in a lawsuit or claim emotional harmor damages in a lawsuit with another entity.
  • In the event of an injury, illness, death, or other unexpected emergency situation that results in me becoming unavailable, your basic contact information (name and contact numbers or email) may be provided to a fellow clinician or associated professional. This will allow for your timelynotification of appointment cancellations, as well as provide you with an opportunity to obtain further information regarding your care.

Considering all of the above exclusions, if it is still appropriate, upon your request, I will release information to any agency/person you specify unless I conclude that releasing such information might be harmful in any way.

I cannot warrant the security of confidential material that becomes insecure because of such actions you may take

While I regularly check in on the security of all of our ways of communicating, swift advances in technology preclude my ability to be certain of our security. Just as I cannot guarantee a physical office space isn’t broken into, I also cannot guarantee the absolute security of our work online or by phone.

Although reasonable precautions will be taken to protect the privacy of your data, if you choose to use technology such as that available to us through Circady.com, for example, [including app and video software], you agree and acknowledge that your personal data may be stored outside Canada and therefore will be subject to the laws of other jurisdictions and may potentially be accessed by the courts, law enforcement and national security authorities of other jurisdictions. Please also see Circady’s privacy policy at Circady.com. The use of technology such as that provided by Circady.com is not a requirement of undergoing counselling with me and you have the right to opt out and to use alternative methods of communicating and data collection. 

Limiting Use and Disclosure

I will not collect, use, or disclose personal information except for the identified purposes for collection, unless I have received additional consent or the processing is authorized without consent;

I will disclose personal information where authorized by PIPA or required by law (for example, in the event of a court order, subpoena, or search warrant; see exceptions above).

If I retain another organization or individual to do work for me that involves personal information, I will ensure there is an agreement in place that ensures this organization or individual understands and follows the same PIPA obligations.

Iwill keep personal information only as long as necessary to fulfill the purpose(s) for which it was collected, but will keep personal information that is used to make a decision about an individual for at least one year after using it so the individual has a reasonable opportunity to obtain access to it.

I will securely store all records containing personal information, including transcripts, for a period of seven years from the last entry in your counselling record.

Within a reasonable period of time after seven years from the last entry in your counselling record, I will securely destroy or anonymize personal information once it is no longer necessary to fulfil the identified purposes or any other legal or business purposes.

Accuracy

I will make reasonable arrangements to ensure that the personal information you collect, use, or disclose is accurate and complete.

You may request that I correct any errors or omissions in your personal information that is under my control.

If I am satisfied that an individual’s request for correction is reasonable, I will correct the information and send the corrected information to organizations I disclosed that information to during the year before the date the correction was made.

If I am not satisfied that the request for correction is reasonable, I will annotate the information, noting that the correction that was requested was not made.

Safeguards

I will make reasonable security arrangements to protect personal information in my custody or under my control, which will include physical measures, technical tools, and organizational controls where appropriate.

I will take reasonable steps to safeguard personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal, and will protect personal information regardless of the format in which it is held (e.g., paper, electronic, audio, video).

Such safeguards will include:

  • Keeping paper records in a locked storage cabinet
  • Use of encryption software and password protection of electronic records
  • Taking reasonable precautions in selecting and recommending use of technology. This will include giving you the right to decline the use of technology which may store your personal data in jurisdictions outside of Canada.

Your responsibilities in the protection of your privacy

  • I urge you NOT to disclose your password to anyone, or to allow another person to access the system while you are still logged in.
  • I urge you to logout after each use of the site, and to clear your browser’s cache. This is also known as clearing your recent browsing history. (Please refer to your browser’s help menu if necessary.) This helps keep your personal information safe, and is particularly important if others may be using the same computer after you.
  • I advise you to be aware of the security issues related to downloading and storing files to your local computer or to a portable storage device, and if you are not aware of the risks, to avoid doing so. Once a file is stored on your local computer or on a portable storage device, it is unencrypted, and you become fully responsible for safeguarding that file.
  • Please be aware that computer viruses, malware, and even legitimate software products exist that are capable of recording keystrokes. It is good computing practice to always ensure that your computer is running up-to-date antivirus software.

No Warranty

I do not warrant the privacy of confidential material that becomes insecure because of user negligence or actions that users may take or that is a result of software that I did not supply. Examples of security breaches that I do not warrant include, but are not limited to:

  • leaving confidential material on a computer screen for others to see
  • storing confidential material on the local computer or a portable storage device
  • use of monitoring software (for example, by an employer)

While I strive to protect users’ personal information, no data transmission over the Internet is guaranteed to be 100% secure. Thus, I cannot ensure or warrant the security of any information during transmission of data, and users submit information to us at their own risk. However, I do my best to ensure the highest level of security on our systems.

Links to other sites

I may provide links to web sites operated by government agencies, non-profit organizations and private businesses. When you link to another site, this privacy policy will not apply, however, you may be subject to the privacy policy of that new site, if one exists.

I have no control over the third parties, including those whose hyperlinks I allow on my site. These third parties may change their web site content without notice. Clients or visitors who link to any other site do so at their own risk and I am not be responsible or liable for any damages in connection with linking.

Access

You have the right to access:

  • Your personal information;
  • Information about the ways in which your personal information is or has been used; and
  • The names of the individuals and organizations to which your personal information has been disclosed

A request for access must be made in writing.

You may be required to prove your identity before receiving access to your personal information.

I may charge a reasonable minimal fee for providing you with access to your personal information. If a fee is required, I will give you a written fee estimate in advance. I may require payment of a deposit or the whole fee before releasing the requested information.

I will provide requested personal information within 30 business days after it is requested, unless a time extension is granted under PIPA.

If I am authorized or required by PIPA to refuse access, I will tell you in writing, stating the reasons for my refusal and outline further steps that are available to you.

Policy Changes

I reserve the right to change this privacy policy without notice at any time. However, such changes, if made, will adhere to all pertinent legal and ethical specifications. If I make changes to this privacy policy, I will post those changes on this Web site for users to review.

Complaints

If you have a complaint regarding this privacy policy, please contact me:

Lorraine Irlam

604-771-4444

or

via my secure contact form at: https://mytherapyonline.ca/secure-contact-form/

You may be required to prove your identity before discussing any complaint or request that involves your personal information.

If you are not satisfied with how I perform my duties under PIPA, or to seek a review of my response to your access or correction request, you may contact the Office of the Information and Privacy Commissioner. Contact information may be found at: https://www.oipc.bc.ca/about/contact-us/

I, Lorraine Irlam, on the 10th of March, 2019, hereby declare that I will conduct my clinical practice in accordance with these policies and procedures, and the requirements of the Personal Information Protection Act.